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Sanitary Survey Requirements and the Ground Water Rule (GWR)
Ground Water Rule WorkshopDepartment of Environmental Conservation
September 22-23, 2009
Paul Gabbert, PE Sanitary Survey Program Coordinator
DEC Drinking Water [email protected]
Vanessa Wike, PEStatewide Engineering Coordinator
DEC Drinking Water [email protected]
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Sanitary Survey Requirements and the Ground Water Rule (GWR)Presentation Outline:
This presentation outlines the role and scope of Sanitary Surveys relative to the GWR.
The GWR establishes a risk-based approach to ground water systems which are susceptible to fecal contamination, instead of requiring disinfection for all ground water systems.
Periodic Sanitary Surveys are one of five major components of the multiple barrier approach the GWR uses to minimize risk from waterborne pathogens.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)Presentation Outline (cont’d.):
Frequency of Sanitary Surveys (SS).Deficiencies & Corrective Actions:
Definition of a SS and the 8 elements of a SS.Deficiencies in each of the 8 elements.Review of deficiency examples.Identification of corrective actions.
Assessment source monitoring.Impact of the GWR to SS processes.Summary.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)The GWR requires States to conduct SS of
GW Community Water Systems (CWSs) every three years and every five years for non-community water systems.
by December 31, 2012 all CWS will be on 3 year cycles.
The State of Alaska currently requires Non-Community Water Systems to conduct SS every 5 years.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)At this time, we are reviewing existing
deficiencies which require corrective action relative to the GWR, as defined by the State.
The GWR requires each state to define and describe at least one type of specific significant deficiency for each of the 8 SS elements.
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Sanitary Survey Requirements and the Ground Water Rule (GWR) Significant deficiencies include, but are not
limited to, defects in design, operation, or maintenance, or a failure or malfunction of the sources, treatment, storage, or distribution system that the State determines to be causing, or have potential for causing, the introduction of contamination into the water delivered to consumers.
The GWR requires GWSs to correct significant deficiencies.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
Corrective Action Options:1. Correct the significant deficiency.2. Eliminate the source of contamination.3. Provide alternative source of water.4. Provide treatment which achieves 4-log
inactivation or removal of viruses.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
The following slides outline deficiency severity levels as defined by the State of Alaska, and contrasts with the EPA deficiency definition.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
SEVERITY LEVELS Per EPA Rules SEVERITY LEVELS IN AK REGS
Significant- Action in 30/120 days
Critical - Action required in 24 hours
Significant- Action required in 5 days
Deficiency- Action required in 30 days
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
SEVERITY LEVELS Per EPA
Significant- Action in 30/120 days This rule states that significant deficiencies ‘‘include, but are not limited to, defects in design, operation, or maintenance, or a failure or malfunction of the sources, treatment, storage, or distribution system that the State determines to be causing, or has the potential for causing, the introduction of contamination into the water delivered to consumers.’’
(A) The State must provide the GWS with written notification, which describes any significant deficiencies found, no later than 30 days after the State identifies the significant deficiency. (B) GWS must consult with the state on the corrective action plan within 30 days of notification of a deficiency. (C) GWS must correct or be in compliance with a corrective action plan within 120 days.
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
SEVERITY LEVELS IN AK REGS
Critical - Action required in 24 hours“critical deficiency” means a problem with a public water system (A) that has a high probability of resulting in or has resulted in the introduction of contamination into water that by itself could cause imminent system failure, illness, harm, or loss of human life; and(B) caused by a (i) defect in a public water system’s design, operation, or maintenance; or (ii) failure, malfunction, or defect of a public water system’s treatment, storage, distribution, or security system;
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
SEVERITY LEVELS IN AK REGS
Significant- Action required in 5 days“significant deficiency” means a problem with a public water system(A) that has a moderate probability of resulting in or has resulted in the introduction of contamination into water that by itself could pose an acute public health risk; and(B) caused by a(i) defect in a public water system’s design, operation, or maintenance;(ii) failure, malfunction, or defect of a public water system’s treatment, storage distribution or security system;
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Sanitary Survey Requirements and the Ground Water Rule (GWR)
SEVERITY LEVELS IN AK REGS
Deficiency- Action required in 30 days“deficiency” means a problem with a public water system(A) that has a slight probability of resulting in or has resulted in theintroduction of contamination into water that by itself could cause system failure, or a public health risk; and(B) caused by a(i) defect in a public water system’s design, operation or maintenance; or(ii) failure, malfunction, or defect of a public water system’s treatment, storage, distribution, or security system;
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Sanitary Survey Requirements and the Ground Water Rule (GWR)Corrective action must be completed within
timeframes shown in the following slides after receiving notification from the State, or be in violation of the treatment technique requirements of this rule.
For suggestions for complying with GWR requirements and implementing corrective actions, reference:“Ground Water Rule Corrective Actions Guidance
Manual”,
http://www.epa.gov/safewater/disinfection/gwr/pdfs/guide_gwr_correctiveaction.pdf
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State of Alaska Regulation – Critical DeficiencyTimeline begins when deficiency is identified
24 HOURS 24 HOURS Time period designated by State 24 HOURS
Critical Deficiency
identified Third Party Survey Inspector notifies State and Owner by
phone/fax
After receiving notification from Survey Inspector of critical deficiency, PWS Owner to contact DW Program to discuss and plan required corrective action
After consultation with the DW Program the PWS Owner must
complete corrective actions within the time period required
by the State
Corrective Action Completed
PWS Owner to submit in writing how the plan to correct the
critical deficiency was carried out
Third Party Survey Inspector to provide written summary of critical deficiency to State and Owner
48 hours from when Critical Deficiency first identified
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State of Alaska Regulation – Significant DeficiencyTimeline begins when deficiency is identified
5 working days 24 HOURS 5 calendar days or time period designated by State 48 HOURS
Significant Deficiency identified
Third Party Survey Inspector notifies State and PWS Owner
by phone/fax
After receiving notification from Survey Inspector of Significant deficiency, PWS Owner to contact DW Program to discuss and plan required corrective action
After consultation with the DW Program the PWS Owner must
complete corrective actions within the time period required
by the State
Corrective Action Completed
PWS Owner to submit in writing how the plan to correct the
critical deficiency was carried out
Third Party Survey Inspector to provide written summary of critical deficiency to State
and PWS Owner
6 days from when Significant Deficiency first
identified
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State of Alaska Regulation –DeficiencyTimeline begins when report
is received by PWS
30 days 30 days Corrective Action schedule approved by State
Deficiency identified
After inspection Third Party Survey Inspector notes the deficiency in the Survey Report provided to State and PWS Owner
After receiving Survey Survey Report, PWS Owner to respond to DW Program in writing describing corrective action and schedule
Corrective Action
Completed
PWS Owner to submit in writing how the plan to correct the deficiency was carried out
60 days from when Deficiency first identified
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EPA Rules – Significant Deficiency
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Definition of a Sanitary SurveyA SS is a review conducted by the State
(including 3rd party inspectors in Alaska) which looks at 8 specific elements of a public water system.
The goal of a SS is to provide independent inspection of a drinking water system and to educate operators about proper monitoring and sampling procedures, and inform them of any coming changes in regulations.
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8 Specific Elements of a SS include:1. Source;2. Treatment;3. Distribution System;4. Finished Water Storage;5. Pumps, Pump Facilities, and Controls;6. Monitoring, Reporting, and Data Verification;7. System Management and Operation; and8. Operator Compliance with State
Requirements.
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Deficiencies & Corrective ActionsThe following slides outline examples of
significant deficiencies for each of the above 8 elements and identification of possible corrective actions relevant to the GWR.
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Deficiencies & Corrective ActionsSource Deficiency Examples:
1. Well does not meet State-specified setback distances from hazards.2. Well head in flood zone (wells at risk to routine flooding).3. Improperly constructed well.
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Deficiencies & Corrective ActionsSource – Example Corrective Actions:
1. Remove hazards to well or relocate well.2. Address components of well which are not
properly constructed (such as height of casing above ground, screened vent, grouting).
3. Replace or supplement existing well cover with cap which provides a sanitary seal.
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Deficiencies & Corrective ActionsTreatment Deficiency Examples:
1. Inadequate application of treatment chemicals and/or no provisions to notify of chemical feed failure.
2. Inadequate disinfection contact time. 3. No provision to prevent chemical overfeed and/or
no provisions to notify of chemical feed failure.
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Deficiencies & Corrective ActionsTreatment Example Corrective Actions:
1. Written operations and maintenance procedures for water treatment.
2. Supplement disinfectant contact time (e.g., additional storage, slower flows, baffling).
3. Add controls to notify of chemical feed failure and/or eliminate the possibility of chemical overfeeds (e.g., check valves, day tanks).
4. Install and monitor valves or other control measures that allow treatment units to be bypassed; do not serve water to public when bypassing results in inadequately treated water (e.g., does not comply with SDWA requirements).
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Deficiencies & Corrective ActionsDistribution System Deficiency Examples:
1. Negative pressures due to an incident outside of normal operating ranges that could result in the entrance of contaminants.
2. Unprotected cross-connections.
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Deficiencies & Corrective ActionsDistribution System Example Corrective
Actions:
1. Corrective action for cross-connections and/or cross-connection control program.
2. Installation of a backflow protection device to prevent future backflow events.
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Deficiencies & Corrective ActionsFinished Water Storage Deficiency Examples:
1. Inspection and cleaning of storage tanks not included in system operation and maintenance (O&M) plan or failure to inspect and clean storage tanks.
2. Lack of screening of overflow pipes, drains or vents.
3. Storage tanks roofs or covers need repairs (e.g., holes, hatch damage or improper construction, failing floating cover).
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Deficiencies & Corrective ActionsFinished Water Storage Example Corrective
Actions:
1. Corrective action plan for cleaning and maintenance. 2. Corrective action schedule for repairs. 3. Repair screens.
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Deficiencies & Corrective ActionsPumps, Pump Facilities, and Controls
Deficiency Examples:
1. Lack of adequate pumping capacity or emergency power at critical facilities.
2. Cross connections to auxiliary supplies or cooling water. 3. Pump inspection and maintenance not included in
system O&M plan; system does not comply with plan.
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Deficiencies & Corrective ActionsPumps, Pump Facilities, and Controls
Example Corrective Actions:
1. Corrective action plan for installation of required pumping capacity or emergency power.
2. Remove cross connection or install backflow protection.
3. Include pump inspection and maintenance in O&M plan; perform as required.
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Deficiencies & Corrective ActionsMonitoring, Reporting, and Data Verification
Deficiency Examples:
1. Failure to monitor water quality or treatment. 2. Failure to monitor water quality in accordance with
required monitoring plans. 3. Failure to report water quality monitoring. 4. Operators are using improper procedures and/or
methods when collecting samples or conducting onsite analyses.
5. Falsification of sampling records, laboratory, or other data.
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Deficiencies & Corrective ActionsMonitoring, Reporting, and Data Verification
Example Corrective Actions:
1. Monitoring plans or revisions to monitoring plans. 2. Training plan for system staff. 3. Contracts with certified laboratories.
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Deficiencies & Corrective ActionsSystem Management & Operations
Deficiency Examples:
1. Failure to meet water supply demands/interruptions in service.
2. Inadequate technical, managerial and financial resources to continue to reliably operate the system.
3. Inadequate resources for emergency response. 4. Inadequate staffing to ensure proper operation and
system control.
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Deficiencies & Corrective ActionsSystem Management & Operations Example
Corrective Actions:
1. Additional source of supply, new service limits, interconnections or cooperative agreements with nearby systems.
2. TMF capacity development improvement plan. 3. Asset management plan, operations plan, and/or
business plan. 4. Emergency response plans, cooperative agreements.
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Deficiencies & Corrective ActionsOperator Compliance with Certification
Requirements Deficiency Examples:
1. No certified operator where one is required by the State.
2. Operator is not certified at the level required by the State.
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Deficiencies & Corrective ActionsOperator Compliance with Certification
Requirements Example Corrective Actions:
1. Corrective action plan or compliance plan/agreement for certification.
2. Assistance from other PWSs. 3. Contracts or other formal arrangement for certified
operator support.
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Notifications
The GWR requires systems to notify customers of significant deficiencies found in the water system - including the date and nature of the significant deficiency, the schedule for correction, any interim measures taken until corrective action can be completed, and the progress to date.
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Optional Assessment Source MonitoringThe SS will be one source of information for
determining a high risk system.
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Impact of the GWR on the SS requirements for existing PWSsIncreased frequency (from 5 year to 3 year
for CWSs),There are 294 GW CWS in the State.
Increased level of scrutiny (and quality standards for Sanitary Survey Inspectors and Sanitary Survey Reports) by all involved in the SS process, especially in regard to the designation of significant deficiencies requiring corrective action relevant to this rule.
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SUMMARY
Frequency of SS will change to 3 years for CWSs and NTNCWS.Must take corrective action if system has significant deficiencies
identified/noted in the SS.At this time, we are reviewing existing deficiencies as defined by
the State.Corrective action must be completed within specific timeframes
according to severity as defined by the State – if not, the system will be in violation of the treatment technique requirements of this rule.
Assessment source monitoring may be required by the State, based on deficiencies and/or facts discovered during a SS.
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CONTACT INFORMATIONPaul S. Gabbert, PEEnvironmental EngineerDrinking Water ProgramDivision of Environmental Health555 Cordova StreetAnchorage, AK 99501(907)269-7624Email: [email protected]: www.dec.state.ak.us/eh/dw/
